August 27, 2019 - Front Office Committee Meeting Agenda

Meeting Details

  • When: Tuesday August 27, 2019 @ 11:00 AM ET

Meeting Agenda

  • Spotlight Topic: SEC released the FIF requested FAQs on SEC Rule 606.  During this portion of the meeting, we will refer to a recent article written by Chris Montagnino, Managing Director, Jordan & Jordan.
  • FINRA Updates
    • TRACE
      • August 8, 2019: New Vendor Management System for TRACE Vendors;
      • July 26, 2019: Regulatory Notice 19-25 - FINRA Requests Comment on a Proposal to Require Reporting of Transactions in U.S. Dollar-Denominated Foreign Sovereign Debt Securities to TRACE;
      • July 22, 2019: Reminder – Second CTCI Migration Production Test for TRACE and ORF;
    • Additional FINRA Updates
      • August 9, 2019 - Regulatory Notice 19-27 - FINRA is engaged in retrospective rule review of rules related to the exploitation of seniors.  FINRA is requesting industry comment on or before October 8, 2019;
      • August 7, 2019: Regulatory Notice 19-26 - Regulation Best Interest - SEC adopts Best Interest standards of conduct;
  • SEC
    • August 12, 2019: 33-10670 - Investor Advisory Committee Meeting (Thursday, September 5, 2019)
    • August 8, 2019: 33-10668 - Modernization of Regulation S-K Items 101, 103, and 105
  • Exchange Updates
    • August 12, 2019: SR MIAX 2019 36 - Amend Rule 518,Complex Orders, to state that orders and quotes executed in a Complex Auction will be allocated first in price priority based on their original limit price (or protected price, as described in Interpretation and Policy .05, if price protection is engaged).
    • July 26, 2019: NASDAQ - Nasdaq to Introduce New Routing Strategy: Nasdaq Midpoint Seeker
  • CAT
    • August 16, 2019 - FINRA CAT published CAT Connectivity Specs;
    • August 15, 2019 - FINRA CAT to hold webinar on CAT Security on August 28 @ 4:15;
    • August 14, 2019 - FINRA CAT published a presentation and recording on the equity representative order industry outreach call;
    • August 7, 2019 - FINRA CAT Published CAT User Onboarding Guidance;
    • August 7, 2019: FINRA CAT to hold an Industry Webinar - Firm Designated ID (“FDID”) Follow-up on September 10 @ 4:15.  FIF has formed a FDID roundtable in preparation for that meeting;
    • August 7, 2019: Industry Webinar – CAT Error Correction Overview (August 27, 2019);
    • August 1, 2019: CAT Tech Spec Working Group Q&A;
    • July 31, 2019: Industry Member Reporting Scenarios v2.2;

      • FIF Working Group Updates: Please click here to Join Working Groups
        • Consolidated Audit Trail (CAT)
          • Current FIF CAT Workstreams:
            • CAT Tech Spec Review;
            • OTC Equities Reporting;
            • CAT Scenario Development;
            • Phase 2c/2d CAT Event Scoping (paired options and complex options)
            • FDID;
            • CAT Operations.
          • August 15, 2019 - FIF published CAT Cost Survey;
          • August 14, 2019 - FIF met with FINRA CAT and the SROs on CAT OTC Quote Events and the proposed CAT Large Trader Phase 3 Solution;
          • August 13, 2019 - FIF met with FINRA CAT/SROs on Paired Options Orders.  FIF will form a subgroup with the industry associations with the intention of providing detailed feedback to the SROs;
          • July 10, 2019: FIF met with SEC Trading & Markets Staff to discuss industry proposal on Large Trader Rule Phase 3;
          • July 3, 2019:  FIF disseminated a CAT Cost Survey designed to assist industry members in assessing the current and anticipated CAT implemenation spend;
          • June 19, 2019: FIF participated in a focus-group session with FINRA CAT on CAT connectivity options;
          • June 4, 2019: FIF met with SEC Staff and members of Congress to discuss CAT and 606
          • June 3, 2019:  FIF provided FINRA CAT/SROs with recommendations on the CAT Web Portal functionality;
          • April 2, 2019:  FIF submitted a Comment Letter to the SROs on the current CAT implementation schedule and remaining risks; 
          • March 14, 2019: FIF attended an in-person Error Feedback and Correction Working Session with the CAT NMS team;
          • February 4, 2019: FIF submitted a comment letter on the CAT transitional period to the CAT Leadership Committee;
          • December 11, 2018:  FIF submitted comments to the Commission on the current status of CAT;
          • October 1, 2018:  FIF submitted detailed spec review summaries and commentsto the SROs, SEC, and ThesysCAT on V0.6 of the industry member tech spec;
          • CAT NMS Plan Website.
        • 606 Working Group
          • August 19, 2019 - FIF held a 606 working group call focused on discussion of the recently published 606 FAQs and next steps pertaining to a formal request for an extension of the Rule's compliance date;
          • August 2, 2019 - FIF and STA sent a joint-letter to SEC Commissioners and Staff on the current status of Rule 606 implementation and request for relief.
          • June 20, 2019 - FIF met with SEC T&M Staff to review a draft version of FAQs.  
            • FIF's interpretation of the Commission's verbal guidance can be found here.
          • May 2, 2019 - FIF submitted a follow-up request for guidance to the Commission;
          • April 24, 2019 - The SEC granted FIF's request for an extension in the Rule 606 implementation date.  FIF is currently working with the Commission on the development of guidance;
          • April 11, 2019 - FIF met with SEC Trading and Markets staff to discuss remaining SEC Rule 606 challenges;
          • February 20, 2019 - FIF submitted a comment letter to the SEC discussing Rule 606 challenges;
          • February 5, 2019 - FIF met with the SEC Trading and Markets staff to discuss challenges and recommendations attributed to the Amended Rule 606;
          • January 30, 2019 - FIF submitted a comment letter to the SEC raising significant Rule 606 implementation challenges;
          • December 11, 2018 - FIF participated in an open call hosted by the Security Traders Association highlighting the recent amendments to SEC Rule 606.
        • FIF EBS Working Group
          • July 17, 2019 - FIF submitted comments to SEC Staff focused on industry recommendations pertaining to the current EBS request/response systems and considerations for potential surveillance through CAT.
        • TRACE Working Group
          • August 16, 2019 - FIF held a working group meeting with the TRACE working group to solicit industry feedback pertaining to Regulatory Notice 25-19 - FINRAs proposal to include the reporting of U.S. dollar denominated Sovereign Debt Securities to TRACE.  FIF intends to submit comment on or before the September 24 deadline. 
        • Tax Information Working Group
          • FIF formed a working group to discuss, inter alia, industry best practices, increasing tax reporting efficiencies, and leveraging new and evolving technology to revise tax reporting processes.  If you would like to join this working group, please update your profile here.  
        • Retail Execution Quality
          • FIF held a meeting on May 3;
          • FIF submitted comments to the SEC requesting that the Commission review and issue a formal request for comment pertaining to FIF's Rule 605 Modernization Recommendations;
          • FIF 605 Subgroup representatives met with SEC Staff on Tuesday, October 30th to discuss the subgroup's recommendations of rule 605 reform.  Please click here to view the draft.
        • EU Buy-In Working Group
          • FIF will hold our next EU Buy-In call on Tuesday, August 20 at 2pm est.  
        • Cost Basis Working Group
          • We are awaiting guidance from the IRS on crypto and QOFs.
        • Cloud Technology Working Group
          • At our last meeting we were treated to a spotlight topic by Dave Larson from HPE who presented on where he sees the future of cloud technology going in the next 5-10 years. FIFs Kevin McCabe also spent some time introducing the Cloud Technology Best Practices Guide we've been developing this year and took suggestions for additional topics and changes for the document. 
          • Our next meeting is September 13th
        • Data and Technology
          • Next Meeting: August 28;
          • On our next call the spotlight topic will be focused on a research project that our Co-Chair Rob Wallos and the data scientists at HPE have been working on.
        • FIF Cybersecurity Working Group
          • Our last meeting was held on August 15th;
          • The meeting focused on an extremely detailed2019 state of cybersecurity report from Wipro. 
        • FIF Industry Solutions Offering
          • Visit the FIF Industry Solutions Page for the Latest Products & Services from Fellow FIF Members
        • FIF Retail Execution Quality Statistics
        • FIF Regulatory Initiatives Tracking Site - (Requires FIF Website Login)FIF Monthly Reports
          • Market Data Capacity Statistics – (Requires FIF Website Login)
  • Additional Updates - Equities
    • August 16, 2019: NYSEArca - 34-86697 - Notice of Filing and Immediate Effectiveness of Proposed Rule Change to Amend Rule 6.40-O to Reduce the Minimum Allowable Parameter for the Transaction- and Volume-Based Settings in the Risk Limitation Mechanism
    • August 13, 2019: NYSE - 34-86651 - Notice of Filing of Amendment No. 1 and Order Granting Accelerated Approval of a Proposed Rule Change, as Modified by Amendment No. 1, to Amend Section 703.18 of the Listed Company Manual to Permit the Listing of Event-Based Contingent Value Rights and Make Other Changes to the Listing Standards for Contingent Value Rights
    • August 13, 2019: NASDAQ - 34-86642 - Notice of Filing of Proposed Rule Change to Amend Certain Cutoff Times for On-Close Orders Entered for Participation in the Nasdaq Closing Cross and Adopt a Second Reference Price for Limit-on-Close Orders
    • August 8, 2019: NASDAQ - M-ELO Enhancements: Allowing for Odd Lots and Continuous Book Interaction
    • August 8, 2019: NASDAQ - 34-86609 - Notice of Filing and Immediate Effectiveness of Proposed Rule Change to Amend SCAR Credits at Equity 7, Section 118(a)
    • August 7, 2019: NYSEArca - 84 FR 38708 (8/7/19)
    • August 7, 2019: NYSEArca - Proposal to modify Rules 6.60-O and 6.65A-O regarding the treatment of orders subject to Trade Collar Protection.
    • August 7, 2019: NYSEArca - Proposal to amend Rule 6.40-O to reduce the minimum allowable parameter for the transaction- and volume-based settings in the Risk Limitation Mechanism.
    • August 6, 2019: SR-NASDAQ-2019-060 -A proposal to amend Rules 4120 and 4753 to permit the Exchange to declare a regulatory halt in a security
    • August 6, 2019: NYSE Chicago - Proposes trading rules to support the transition of trading to the Pillar trading platform
    • July 31, 2019: SR-NASDAQ-2019-064 - Proposal to amend certain cutoff times for on-close orders entered for participation in the Nasdaq Closing Cross and adopt a second reference price for limit-on-close orders.
    • July 30, 2019: NASDAQ - 34-86512 - Notice of Designation of Longer Period for Commission Action on Proposed Rule Change, as Modified by Amendment No. 1, to Amend Rule 4702 to Establish the "Midpoint Extended Life Order + Continuous Book" as a New Order Type
    • July 26, 2019: NYSE National: Market Data Feed migration to Pillar Publishers
    • July 24, 2019: NYSE - 34-86460 - Notice of Designation of Longer Period for Commission Action on Proposed Rule Change to Amend Exchange Rule 104 to Specify Designated Market Maker Requirements for Exchange Traded Products listed on the Exchange
    • July 23, 2019: NASDAQ - 34-86437 - Notice of Filing and Immediate Effectiveness of a Proposed Rule Change to Amend Its Rules Governing the Nasdaq Options Market to Modify the Give Up of a Clearing Participant by a Participant on NOM transactions
  • Additional Updates - Options
    • August 16, 2019: Phlx - 34-86695 - Notice of Filing and Immediate Effectiveness of Proposed Rule Change to Amend Exchange Rules 605 and 1049
    • August 14, 2019: 34-86662 - Notice of Filing and Immediate Effectiveness of a Proposed Rule Change Relating to Clarify Portions of its Rules Under Chapter 14 (Securities Traded) Related to the Applicability of Certain Disclosure Requirements
    • August 14, 2019: 34-86667 - Notice of Filing and Immediate Effectiveness of a Proposed Rule Change to Introduce a Small Retail Broker Distribution Program
    • August 14, 2019: 34-86664 - Notice of Filing and Immediate Effectiveness of a Proposed Rule Change Relating to Clarify Portions of Rule 14.11 (Other Securities) Related to the Applicability of Certain Disclosure Requirements
    • August 9, 2019: 34-86617 - Notice of Filing and Immediate Effectiveness of a Proposed Rule Change to Amend the Ability to Submit Frequent Trader Forms
    • August 9, 2019: 34-86623 - Notice of Filing and Immediate Effectiveness of a Proposed Rule Change Relating to Rule 14.3(e), Additional Requirements for Securities Issued by the Exchange or its Affiliates
    • August 9, 2019: 34-86621 - Notice of Filing of a Proposed Rule Change to Adopt Rule 21.21 (Solicitation Auction Mechanism)
    • August 8, 2019: 34-86603 - Notice of Filing of a Proposed Rule Change Relating to Adopt Rule 6.49B, Off-Floor RWA Transfers
    • August 7, 2019: SR EMERALD 2019 30 -Amend Rule 520, Limitations on Orders, to remove certain order entry restrictions on Electronic Exchange Members ("EEMs")
    • August 5, 2019: 34-86567 - Notice of Designation of Longer Period for Commission Action on a Proposed Rule Change to Introduce a Liquidity Provider Protection on EDGA
    • July 31, 2019:NYSE Options: New OPRA Trade Message Codes - Market Data Specification Update
    • July 23, 2019: 34-86444 - Notice of Filing and Immediate Effectiveness of a Proposed Rule Change to Amend its Rules Governing Give Ups on the BX Options Market
    • July 23, 2019: 34-86432 - Order Granting Accelerated Approval of a Proposed Rule Change to Adopt Rules to Permit Cboe Trading, Inc. to Become a Trading Permit Holder and an Inbound and Outbound Router of the Exchange
  • Next Meeting Date: Tuesday, September 24th, 2019 @ 11:00 am ET.

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